Waiting for SBTi: A Formal Request to Reinstate the Original Method

Continuing my commitment to transparently document my ongoing engagement with the Science Based Targets initiative (SBTi) encouraging it back into integrity, I'm posting my latest response to SBTi CEO Luiz Amaral (see my previous response here, and prior engagement with SBTi here, here, here,?and here). To understand the context of my response, I start out here with the key paragraph from Dr Amaral's 14 April 2022 response to me:

Under the SBTi’s previous model, final decisions required unanimous approval from the Steering Committee with representatives from the four founding partner organizations. The decision on which methods are eligible for SBTi validation was aligned with the rightful governance and due process at that time. Additionally, the methods have been?justified?in a peer reviewed?journal, which also had?a reply. I would also like an opportunity to highlight that such public technical debate in scientific journals is vital to the continual improvement of knowledge. As an advocate of scientific method and leading a science-based organization, I do encourage it to continue and would like to highlight the value of all these authors' contributions.

And now, before posting my response in full, I need to provide one background note: the Center for Sustainable Organizations (CSO) Context-Based Carbon Metric established the practice of assessing corporate greenhouse gas emissions in the context of the thresholds proposed by the climate science community, allocated to the organizational level, through its work with Unilever subsidiary Ben & Jerry's in 2006 (see here, and p49 of this UN report for documentation). The Science Based Targets initiative established itself on the foundation of this thresholds & allocations approach (that CSO Executive Director Mark McElroy established in his 2008 doctoral dissertation), and included CSO amongst the methods that qualify for use under SBTi (along with other methods created independent of SBTi, and two methods created by SBTi partners).

Then, in early 2018, SBTi abruptly disqualified the independent methods (including CSO) from qualification, without having engaged the creators of the independent methods, and without engaging SBTi's Technical Advisory Committee (which all the independent method creators served on at the time). The CSO method in particular met all the criteria that SBTi set. Since 2018, I have been requesting the data and analysis upon which SBTi made this drastic decision, but SBTi has continually refused to disclose this information (as I explain in excruciating detail in my Formal Complaint and Memorandum.)

Now, the full text of my latest message to SBTi:

18 April 2022

Dear Luiz,

Thank you for your response — I appreciate the flow of engagement, in contrast to many historical instances of lapsed responses from SBTi leadership.

I also appreciate your explanation of the?process?of the decision-making on which methods are eligible for SBTi validation, as this provides contextual information that I didn’t previously have. However,?this is?not what I requested. As I made clear several times in this thread, I am requesting “the?evidence upon which SBTi based its original decision (circa 2018) to recommend?for?certain methods and?against?others,” which your message?does not provide. Unfortunately, your failure to provide the requested information fits into a persistent pattern of?side-stepping and obfuscation by SBTI leadership. I hope that your tenure as CEO will support a shift away from this pattern.?

I want to keep focus on my?actual?request, but I would be remiss if I didn't clarify that?the information you?do?provide still falls far short of justifying the decision to disqualify the CSO method, on 3 counts — it’s?ex post facto, and it exhibits?2 forms of method bias. To maintain focus, I’m going to explain these 3 shortcomings below my signature.?

Back to my request: I’m seeking the?data?and?analysis?that SBTi used?at the time?as the basis for?the decision to exclude economic allocation methods — including the CSO method (circa early 2018). SBTi leadership has kept these data and analysis?secret?for more than four years, repeatedly rebuffing requests (a dynamic that you continue),?raising legitimate questions as to?why???One reasonable explanation is that?the?data and analysis never existed, so they can’t be supplied; another reasonable explanation is that?the data and analysis don’t actually support the decision, so SBTi is loathe to expose its own corruption.?The only way to rule out these explanations is to transparently disclose the data and analysis.?

Transparent access to these data and analysis are necessary for independent assessment of the validity / legitimacy of the decision. The Bj?rn?et al?Study and Response support the case that the SBTi rationale for disqualifying the CSO method lacks sufficient support to conclusively justify its validity and legitimacy (as I explain below my signature).?

Accordingly, I now make a?Formal Request to reinstate the CSO method as?fully eligible?for use by companies seeking SBTi target validation?— ie, the same status as ACA and SDA. I ask that this decision be pursued by whatever non-unilateral mechanism SBTi has in place to make all the other decisions it makes in the course of its normal operations. Stated differently, if SBTi’s governing structure enabled it to make the decision to?disqualify?the CSO method in the past, then its governing structure?must?enable it to make?the decision to?qualify?the CSO method now.?

I would be glad to submit a brief case for this decision. Furthermore, I ask that the rationale for the ultimate decision be open to public examination and scrutiny.?

I look forward to hearing back in a reasonable amount of time. I would appreciate immediate confirmation?of receipt of this message, accompanied by a proposed timeline within which you will share details on the process for decision-making on the re-instatement of the CSO method.?

Of course, there are many other governance concerns, so I will end with yet another note of appreciation that you are pursuing necessary governance enhancements to provide mechanisms to resolve these concerns.?

Best,

Bill

Shortcomings in the information provided to?justify the SBTi decision to disqualify the CSO method.

• Ex Post Facto: First, and most obviously, the materials you share (the SBTi Comment and the?Bj?rn?et al?Response)?post-date the original decision by several years, so they represent an?ex post facto?attempt to justify the decision.
• Method Bias 1: Second, SBTi?continues to exhibit Method Bias?— the March 2022 SBTi?Comment?(on the February 2021?Bj?rn?et al?Study) prominently claims that "allocating global emissions based on economic growth yields incoherent results,” yet the March 2022 Bj?rn?et al?Reply?points out that?"SBTi presents this as a unique problem for the CSO method, but both Krabbe et al (2015) (co-authored by one of the Comment's authors) and our study (Bj?rn et al 2021) contain examples of the SDA method allowing companies to increase emissions.” I have pointed out?to SBTi numerous times?that the possibility of emissions increases applies to?all?methods, including in my November 2019 email message to Alberto Pineda Carillo, as well as in my March 2021 Memorandum, yet SBTi continues to apply this concern asymmetrically.?SBTi is clearly exhibiting method bias, as it disqualifies independent methods on a dynamic that equally applies to the non-independent (ie SBTi-created) methods.
• Method Bias 2: Third, SBTi exhibits yet another form of Method Bias by tailoring a?new?set of SBT method evaluation principles to its own methods (ACA and SDA), instead of developing Principles that would apply universally (ie that would treat CSO and other methods in fair, unbiased ways). The?Bj?rn?et al?Reply identifies this bias in an interrogative fashion: "Should evaluation principles be universal or tailored to the current basket of SBT methods? (SBTi's proposed principles appear to make several implicit references to the SDA method through specific criteria for 'heavy-emitting sectors'.)” The pattern of SBTi favoring its own methods, and “stacking the deck”?against?independent methods appears yet again, further invalidating SBTi’s attempt to justify its asymmetric method bias.?